I am writing to express my strong opposition to the proposed amendment to 18VAC85-120-110, which would allow athletic trainers to perform dry needling.

Dry needling is an invasive procedure that requires extensive anatomical knowledge and specialized clinical training to be performed safely and effectively. Licensed acupuncturists undergo rigorous education and hands-on training to develop the skill and precision necessary to avoid serious complications such as infection, nerve injury, or pneumothorax. Allowing individuals without this level of training to perform dry needling poses a significant risk to public health.

This proposal compromises patient safety, exposes the Board of Medicine to increased liability, and undermines the standards established by Virginia law and regulation for the practice of acupuncture. I urge the Board to reject this amendment and to uphold the protections that ensure only qualified and properly trained professionals are authorized to perform needling